There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an explicit 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 clearly 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 the board is ultimately responsible for the oversight of the company's ethics and compliance programme. This includes reviewing reports from management on the programme\u2019s performance along with the results of audits, and there is evidence that the board has the authority to require that any necessary changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the company\u2019s Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's ethics and compliance programme. It is clear this person has a direct reporting line to the board, which provides oversight of the programme.\t<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no clear publicly available evidence that the company reviews risk assessments on at least an annual basis with the results also reviewed at board level.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company's ethics and compliance programme is subject to regular audit and review. There is evidence indicating that this includes measures for continuous improvement, supplemented by an internal audit on an annual basis. There is also evidence that high-level audit findings are presented to the board and Audit Committee, with ownership assigned to individuals for planned updates and improvements to the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases. The company\u2019s compliance department conducts investigations.<\/p>\n
However, in publicly available evidence the company does not cover the whole investigation process from receipt to final outcome. There is also no clear publicly available evidence that a central body reviews the status of all investigations on at least an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no clear 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 commits to report material findings of bribery and corruption from investigations to the board. The company states that its Compliance Officer may report violations to the company CEO, but it is not clear whether this is required. In addition, while the company refers to potential criminal prosecution for violations of its Code of Conduct, there is no clear public evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
While the company publishes some data on disciplinary actions and reports received through its whistleblowing channel, there is no clear evidence that this includes data on ethical or bribery and corruption investigations. The company also does not publish further information on its investigations, such as the number of reports received and number of investigations launched. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides an annual training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the training is provided to all employees in all relevant divisions and jurisdictions. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to the categories of employees referred to in the question. There is evidence that employees working in high risk positions are required to refresh their training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme through staff surveys. There is also evidence indicating that the company conducts reviews on an annual basis and that the results are used to update the company's anti-bribery and corruption programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s incentive schemes for employees incorporate ethical principles. The company indicates that it incentivises its employees to comply with its ethics programme and report violations of its ethics policies. <\/p>\n
However, in publicly available evidence, the company provides limited details on how it rewards this behavior or structures its incentives. It is also unclear whether the company uses financial rewards in high risk departments to incentivise sales and, if so, whether these rewards must be proportionate to the employee\u2019s salary. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company makes a public commitment to protecting whistleblowers even when it might result in a loss of business. However, there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means. <\/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 both whistleblowers and employees who report bribery and corruption incidents. There is evidence indicating that this commitment extends to business partners of the company. <\/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":"2","comments":"
Based on publicly available information, there is evidence that the company has whistleblowing and advice channels, including anonymous and confidential channels. The channels are available to all employees and there is evidence indicating that they are also open to business partners of the company. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy which covers actual conflicts of interest. The policy covers employee relationships and other employment. There is evidence the policy applies to all employees and board members. <\/p>\n
However, in publicly available evidence, the company does not refer to potential or perceived conflicts, nor does it clearly cover conflicts associated with financial interests and government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures in place to deal with conflicts of interest in certain instances. <\/p>\n
However, the evidence is incomplete regarding a broader policy or set of procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts, across all areas of its operations. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company conducts some screening of civil servants before employment. However, there is no evidence that the company has a specific policy regulating the employment of current or former public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
There is evidence that the company publishes a statement that it does not enter into contractual relationships with current or serving politicians in the conduct of business. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, the company publishes a clear statement that it prohibits corporate political contributions. There is evidence to indicate that this policy applies to donations of any kind, and that it applies to all employees and divisions across the group. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company states 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 covering both charitable donations and sponsorships. The company\u2019s policy includes specific criteria and procedures for donations. However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes full details of its charitable donations, such as name, amount and country of each recipient entity. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes a statement to indicate that it does not engage in lobbying activities or employ lobbyists in the conduct of business, in accordance with relevant laws in Korea. <\/p>\n
The company receives a score of \u20181\u2019 because it is not clear from publicly available information whether this approach also applies to any lobbing activities conducted in other jurisdictions. There is no publicly available evidence that the company publishes a clear policy to regulate its lobbying activities in other jurisdictions, nor does it publish a statement to indicate that it does not lobby outside Korea.<\/p>\n"},{"question":79,"commitment_area":11,"score":"N\/A","comments":"
There is evidence that the company publishes a statement to indicate that it does not engage in lobbying activities or employ lobbyists in the conduct of business, in accordance with relevant laws in Korea. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea.<\/p>\n"},{"question":80,"commitment_area":11,"score":"N\/A","comments":"
There is evidence that the company publishes a statement to indicate that it does not engage in lobbying activities or employ lobbyists in the conduct of business, in accordance with relevant laws in Korea. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy specifies financial limits for different types of promotional expenses and it addresses the risks associated with gifts and hospitality given to public officials. <\/p>\n
However, there is no clear publicly available evidence that all gifts and hospitality are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s procurement department is responsible for the establishment of supplier relationships. <\/p>\n
However, based on public evidence, it is not clear that the procurement department is the main body responsible for oversight of the company\u2019s supplier base. There is also no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on its suppliers, and that this includes checks on ownership.<\/p>\n
However, there is no clear evidence that anti-bribery and corruption due diligence is repeated at least every two years on whenever there is a change in business relationship. There is also no evidence that the highest risk suppliers are subject to enhanced due diligence. In addition, there is no public 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":"2","comments":"
Based on publicly available information, there is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company\u2019s Code of Conduct applies to business partners, which can be understood to include suppliers. The Code of Conduct includes prohibition of bribery and facilitation payments as well as policies related to conflicts of interest, gifts and hospitality and whistleblowing. The company requires suppliers to pledge to comply with the ethical rules that the company has set. There is evidence indicating that the company assures itself of this when onboarding new suppliers and periodically monitors third parties\u2019 compliance with its anti-bribery policies. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no clear 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 or disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has a policy covering the use of agents.<\/p>\n
However, in publicly available evidence, the company does not address in any detail the corruption risks associated with the use of agents. There is no 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. There is also no evidence that the company\u2019s policy applies to subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence prior to engaging with its third parties and agents. <\/p>\n
However, there is no clear evidence 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 clear evidence that agents and the highest risk intermediaries are subject to enhanced due diligence.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is evidence that the company asks agents to disclose their beneficial ownership to the company as part of its due diligence processes. However, there is no clear evidence that the company verifies this information, nor that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence indicating that the company\u2019s anti-bribery and corruption policy applies to business partners, which can be understood to include agents and intermediaries. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company addresses 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 associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence prior to entering all of its joint ventures. There is evidence indicating that this includes checks on the ownership of the company.<\/p>\n
However, there is no evidence that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence, nor that due diligence is repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures. The company\u2019s Code of Conduct applies to joint ventures. The company includes anti-bribery and corruption contractual terms in its contracts with joint ventures, which include audit and termination rights. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no clear 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 evidence that the company makes a public statement that it does not engage in offset trades, however there is also evidence on the company\u2019s website to indicate that it engages in industrial cooperation activities and strategic partnerships as part of offset requirements set by purchasing customers; as such, the company\u2019s position on offsets is unclear. <\/p>\n
Although there is some evidence that the company has a dedicated team to manage its industrial cooperation and offset projects, it is not clear from publicly available information that employees in this team receive dedicated anti-corruption or compliance training based on the possible risks associated with offsets. There is also no clear evidence that the company has a procedure in place to manage offsets, nor is there evidence that its industrial cooperation team is responsible for monitoring and oversight of the company\u2019s offset activities throughout the lifecycle of each project.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations or industrial cooperation requirements.<\/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 and industrial cooperation programme, nor does it publish a statement that it does not engage such entities. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is evidence that the company provides some information on the types of offset or industrial cooperation projects that it may engage in, as well as indicating that it engages in relevant strategic partnerships. However, there is no clear public available evidence that the company publishes further details about its offset or industrial cooperation projects, whether direct or indirect, or about the beneficiaries of such projects.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets, nor that it has a risk assessment procedure in place to identify such risks.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes lists of its consolidated subsidiaries and non-fully consolidated holdings. The company\u2019s lists indicate the percentage ownership and the countries of incorporation for each entity. There is evidence that these lists are updated on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes the country or countries of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes information on the entities with significant holdings in the company. In its annual report the company states that approximately 60% of its equity is held by institutional investors, with only one shareholder having a stake higher than 25%. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not disclose this information in an open data format and there is no evidence that its information is available through a national or global corporate register. Although the company is publicly listed in South Korea, its voting shares are not admitted to one of the regulated markets specified in the guidance.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes information on its defence sales by customer. The company publishes some information on its overall revenue from its defence business, however there is no evidence that it provides any details on its major customers.<\/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\/850","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=850"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=850"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}