The company publishes a clear statement in support of high ethical standards and integrity, which is signed by its Chairman and CEO. This commitment appears in the company\u2019s Code of Conduct, which contains the company\u2019s anti-corruption policy that applies all employees within the organisation. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a Code of Conduct, which explicitly prohibits bribery, payments to public officials, commercial bribery and facilitation payments. The company indicates that its 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":"
There is evidence that a designated board committee \u2013 the Nominating and Governance Committee \u2013 is responsible for providing oversight of the company\u2019s anti-bribery and corruption programme. There is evidence that the committee\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance and it is clear that it has the authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 the company\u2019s VP and Corporate Ethics Officer, also referred to as the Director of Ethics and Compliance \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person is at executive level and has a direct reporting line to the board through interaction with the Nomination and Governance Committee, which 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, through attendance at meetings of the Nomination and Corporate Governance Committee.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
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 results of risk assessments are reviewed by the board-level Audit Committee on an annual basis or when significant findings are identified. The company states that the results of such reviews 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":"2","comments":"
There is evidence that the company\u2019s entire anti-bribery and corruption programme is subject to a regular audit to ensure the programme is consistent with best practice and the business risks facing the company. This includes provisions for continuous improvement, supplemented by an internal audit. There is also evidence to indicate that internal audits are conducted on an annual basis and that high-level audit findings are presented to the Audit Committee and the Nomination and Governance Committee. There is evidence that the company has management structures in place to implement recommended changes from audits.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and there is evidence that it has procedures in place to deal with whistleblowing cases. The company establishes dedicated ethics and compliance review boards composed of senior management to consider any reports received. There is evidence that summary information on investigations is reviewed by the Nominating and Governance Committee of the board of directors periodically, which is understood to indicate at least once annually. The company also indicates that it provides whistleblowers and those who report concerns with updates on the outcome of investigations. <\/p>\n
However, the company receives a score of \u20181\u2019 because in publicly available evidence it does not stipulate documentation and actions to be taken at each step or provide clear details covering the entire investigation process, from receipt to final outcome. There is also no publicly available evidence on how the company ensures the independence of its investigations, for example by stating that reports are handled by an independent team or that the team reports to an independent board member. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. There is evidence that the company reviews all compliance and anti-corruption procedures at least every two years, as well as subject to testing by regular internal audits. The company also indicates that it has a procedure in place to handle complaints about the investigation process, stating that employees may contact the Vice President of Internal Audit or the General Counsel in such cases. <\/p>\n
Although the company does not explicitly state that staff conducting investigations are properly trained to perform this function, there is sufficient evidence that it the ethics review boards or the Nomination and Governance Committee may engage independent and in-house legal expertise in the investigative process. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence the company commits to reports material findings of bribery and corruption from investigations to the board. The company also indicates that it will report identified instances of criminality to law enforcement.<\/p>\n
However, the company receives a score of \u20181\u2019 because ownership for this process is unclear; there is no clear 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":"
There is no evidence that the company publishes any data on ethical or bribery and corruption reports, investigations or associated disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that all employees must complete anti-corruption focused training and that this training programme covers the company\u2019s Code of Conduct, which includes the whistleblowing options available to employees. The company states that all employees complete training on joining the company and periodically thereafter. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available evidence that anti-corruption training for employees is provided across all of its operations and geographies, and in all relevant languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence the company provides targeted anti-corruption training to certain employees based on an their specific role and exposure to corruption risk. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information to indicate that this includes all three categories of employee as identified in (a), (b) and (c) in the question. In addition, thile the company states that this training is provided periodically, there is no evidence that employees in high risk positions specifically must refresh their anti-corruption training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company\u2019s anti-corruption communications and training programme is subject to regular review and that, along with all elements of the anti-corruption programme, it is updated when gaps or possible improvements are identified. The company indicates that it monitors these processes on an ongoing basis, with a full review at least every two years. <\/p>\n
The company receives a score of \u20181\u2019 because it does not provide further publicly available evidence of how it measures the effectiveness of its anti-corruption communications and personnel training programme, for example by conducting staff surveys or other awareness activities.<\/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":"1","comments":"
There is evidence that the company commits to support and protect employees to speak up and \u201cdo the right thing\u201d, and never compromise its values in order to achieve business objectives. This commitment appears in the form of a clear statement from the Chairman and CEO, and its commitment to ethical business conduct is reiterated throughout its anti-corruption materials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it assures itself of its employees\u2019 confidence in this commitment through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, as outlined in the company\u2019s Code of Conduct. There is evidence that this commitment extends to all third parties, which are also able to access the company\u2019s whistleblowing line. There is evidence that company assures itself of employees\u2019 confidence in this commitment by monitoring usage statistics from its reporting line. It is noted that the company does not publish high-level usage data on its reporting line.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides both whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-bribery and corruption programme. The company states that reports and questions may be submitted confidentially and anonymously. There is evidence that its channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external body through an independently-operated ethics hotline. <\/p>\n
In addition, the company indicates that its channels are available to all employees and external parties, such as suppliers, joint venture partners and other third parties, as well as in multiple languages and in all relevant geographies across its operations.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence the company formally addresses conflicts of interest as a corruption risk, and that it has a clear policy to define conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy covers possible conflicts arising from government relationships, employee relationships, financial interests, and outside employment. There is evidence that this policy applies to all employees, directors and any third parties with which the company does business. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that its Human Resources and Ethics and Compliance departments are responsible for reviewing conflicts of interest declarations and for the subsequent management of individual cases. In addition, the company states that disciplinary measures apply for violations of the company\u2019s Code of Conduct, which outlines the company\u2019s policy on conflicts of interest.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it has a dedicated central register for all employee and board member declarations, which is accessible to the teams tasked with managing conflict of interest cases. The company also does not provide examples of possible criteria for recusals.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that it requires a legal review prior to hiring former public officials, and indicates that employees must consult with management before initiating employment discussions with current or former government employees. There is some evidence to suggest that such pre-employment reviews include an assessment of actual or potential conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it may impose restrictions on the activities of former public officials once appointed, based on the results of a conflict of interest review. There is also no clear evidence that the company requires a cooling-off period of at least 12 months before public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes 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 has a policy on corporate political contributions. The company indicates that political contributions are generally restricted due to legal prohibitions in many jurisdictions, but where they are permitted such donations require sign-off from the Legal Department and the Government Relations Office. There is evidence that any contributions to, or in support of U.S. Federal office candidates are generally prohibited and indicates that any state or local level donations are highly regulated and must be approved in advance. There is evidence that this policy is applicable to all employees and board members, as well as those employed by the company as third parties. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of employees from different business divisions.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 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 corporate political contributions or Political Action Committee (PAC) disbursements for the most recently reported financial year.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on charitable donations. The company indicates that its board-level Nominating and Governance Committee reviews its charitable donations and philanthropic activities to ensure that they are consistent with the company\u2019s ethical commitments and policies. In addition, the company publishes some information on the charitable causes it supports. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes full details of its charitable donations and related activities, such as the name, amount and country of each recipient as well as which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying which apply to all employees, directors and third parties engaged in lobbying on the company\u2019s behalf. The company indicates that its Government Relations Office is responsible for oversight of all lobbying activities and for contracting any external lobbyists.<\/p>\n
However, the company receives a score of \u20181\u2019 because in publicly available evidence it does not provide details of specific oversight mechanisms or controls to regulate its lobbying activities, nor does it outline certain standards of lobbying conduct which are expected of its lobbyists. It is noted that the company has a dedicated policy on lobbying which may contain more details on these standards, but this does not appear to be publicly accessible. <\/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 on its website. The company states that it complies with all annual lobbying disclosures required by law in the United States, however it does not provide a direct link to its disclosures nor does it provide information on its lobbying aims and activities outside the United States (if any). <\/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. The company states that it complies with all annual lobbying disclosures required by law in the United States, however it does not provide a direct link to its disclosures nor does it provide information on its lobbying aims and activities outside the United States (if any). <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence the company has a policy regulating the giving and receipt of gifts and hospitality, to ensure that such expenses are not used as vehicles for bribery. The company\u2019s policy also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from public officials.<\/p>\n
In addition, the company indicates that it has a separate policy document which provides further procedures and establishes financial limits for different sorts of gifts and promotional expenses. There is evidence that all gift and hospitality submissions above a designated financial threshold are recorded centrally in the company\u2019s Business Courtesy Request System. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s procurement department oversees and manages all the company\u2019s procurement activities, and that this body is the main body responsible for coordinating procurement activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself that proper procedures regarding the onboarding of suppliers are followed through a clearly stated means, such as an audit, at least 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 conduct risk-based anti-corruption due diligence on all third parties, which includes its suppliers. There is evidence that the company establishes ultimate beneficial ownership as part of due diligence and that it performs enhanced due diligence on any suppliers and third parties identified as high risk. <\/p>\n
However, there is no clear evidence that the company conducts due diligence on suppliers at least every two years or when there is a significant change in the business relationship. It is also not clear from publicly available information that the company may be willing to review and or\/terminate supplier relationships when red flags highlighted in the due diligence process cannot be mitigated. It is noted that the company has a separate policy detailing its due diligence procedures and requirements, but this document does not appear to be publicly available. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must have policies in place that prohibit foreign and domestic bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company publishes a Supplier Code of Conduct which applies to all third parties and business partners, and indicates that all suppliers must meet, at a minimum, the standards laid out in this document. In addition, there is evidence that the company ensures this compliance at the start of the business relationship and through periodic reviews thereafter.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company encourages suppliers to flow down the principles and standards outlined in its Supplier Code of Conduct to subcontractors. The company also expects its suppliers to ensure that their anti-corruption standards are maintained throughout their supply chains, for instance by performing due diligence on the third parties with which they engage. <\/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 related reports, investigations or 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 on the use of agents, as part of its policy on third parties. As part of its approach, the company states that it commits to establish and verify whether the use of an agent is necessary to perform a legitimate business function. In addition, there is evidence that the company has specific controls in place to regulate their use, including enhanced risk-based due diligence. There is evidence that this policy applies group-wide to all employees and divisions that may employ agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with agents and intermediaries. There is evidence that higher risk agents or intermediaries are subject to enhanced due diligence, and there is some indication that the company commits to not engage or terminate its engagement with third parties that engage in improper conduct.<\/p>\n
Although the company indicates that it conducts period renewal reviews of its third parties, there is no clear evidence that due diligence on agents is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents and intermediaries prior to engaging them. The company indicates that it has procedures to independently verify the beneficial ownership of agents based on an assessment of risk. In addition, there is some indication that the company may review its engagement with third parties if information highlighted in this process is unclear or depending on the possible risks. <\/p>\n
The company receives a score of \u20181\u2019 because there is no clear evidence it commits to not engage or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all third parties acting on for or on its behalf, including agents and intermediaries. The company publishes a Supplier Code of Conduct, which requires all third parties, including agents, to adhere to equivalent ethical standards. There is evidence 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":"1","comments":"
There is some evidence the company addresses and considers incentive structures for agents as a factor in corruption risk. The company states that it has a procedure to review any proposed compensation structures before engaging with third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on the way that it incentivises agents. For example, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it requires that remuneration be 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 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 reports, investigations or associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
The company states that it conducts risk-based due diligence on all third parties that pose a heightened corruption risk to the company. There is evidence to suggest that high-risk third parties are subject to enhanced due diligence and that the company seeks to establish the ultimate beneficial ownership of third parties. Although it does not specifically mention joint ventures in its list of entities considered to be third parties, the company references \u201cbusiness partners\u201d and this is understood to cover joint venture partners. <\/p>\n
Although the company indicates that it conducts period renewal reviews of its third parties, there is no clear evidence that due diligence on joint ventures is repeated at least every two years or when there is a significant change in the business relationship. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence the company establishes and implements anti-bribery and corruption policies with all of its third parties, including joint venture \u201cbusiness partners\u201d. The company indicates that all third parties with which it does business must follow its Supplier Code of Conduct and indicates that partners should implement equivalent standards. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available information that it commits to establishing and implementing anti-corruption procedures in joint ventures in which it has an ownership stake. It is also not clear that the company\u2019s contracts with joint venture partners include anti-corruption clauses with audit and termination rights; the company\u2019s publicly available information indicates that such clauses apply specifically to intermediaries.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, beyond ensuring that such partners follow its Supplier Code of Conduct. This could include, for example, stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is some evidence that the company recognises the corruption risks associated with offset contracting, and there is evidence that it has a dedicated policy in place to regulate such activities. The company indicates that its Global Business Development team is responsible for implementing and monitoring compliance in relation to offset activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that employees within this team receive specific anti-corruption training on the potential corruption risks associated with offsets. It is noted that the company has a separate policy on offset obligations which may contain more information on its approach, but this does not appear to be publicly available. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations, as part of its overall policy on third parties. There is evidence that the company conducts checks on beneficial ownership of the partner entity and seeks to assure itself of the legitimacy of the investment as part of this due diligence.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its due diligence for offsets includes checks on conflicts of interest. While the company refers to periodic renewal reviews of third parties, there is also no evidence that the company refreshes due diligence at least every two years or when there is a significant change in the business relationship or nature of the partner.<\/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 indirect offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company acknowledges the increased corruption risks of operating in different markets. However, the company scores \u20180\u2019 because there is no clear publicly available evidence that risk assessments are used to develop tailored mitigation plans or to inform the company\u2019s operations in high risk markets. <\/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 on an annual basis. For each entity, the company indicates its full registered name and country of incorporation. The list indicates which subsidiaries are not wholly-owned by the company. <\/p>\n
However, there is no evidence that the company publishes the specific percentage ownership for each entity that is not wholly-owned, nor does it publish information on the country or countries of operation for each entity. It is also not clear that this list represents all of the company\u2019s holdings. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to publish further information on its beneficial ownership in order to receive a score of \u20182\u2019. The company also discloses all shareholders with a stake greater than 5% in its Annual Report.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes some information on its sales by customer, to indicate that the United States government accounted for 77% of its total sales in its most recently reported financial year. The company indicates that its sales primarily relate to defence products and services, though it does not clearly distinguish between its defence and commercial sales. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes information on its major customers for defence sales specifically. <\/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\/853","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=853"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=853"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}