There is evidence that the company\u2019s Chairman and CEO makes a public statement in support of high ethical standards. There is clear evidence that this individual supports and endorses the company\u2019s Code of Conduct, which contains the company\u2019s policy to prohibit all forms of bribery and corruption within the organisation.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and directors, and there is evidence to indicate that this extends to all individuals as listed in (a) and (b) in the question. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s Ethics and Corporate Responsibility Committee is ultimately responsible for oversight of the anti-bribery and corruption programme. There is clear evidence that this committee engages in formal oversight functions, including reviewing reports from management and audits, and that it has the authority to require that any necessary changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s Chief Ethics and Compliance Officer is responsible for managing its anti-bribery, corruption and ethics programme. It is clear that this individual has a direct reporting line to the Ethics and Corporate Responsibility Committee, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between the Chief Ethics and Compliance Officer and the board as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s Ethics Review Board meets quarterly with an Enterprise Risk Management Committee to discuss ethics matters and compliance matters. The company indicates that purpose of the meetings is to review and strengthen the programme and that this committee is composed of senior individuals. <\/p>\n
However, there is no clear publicly available evidence that this review process specifically includes a bribery and corruption risk assessment procedure that informs the design of the ethics and anti-corruption programme. it is also not clear from publicly available information that the results of risk assessments are reviewed by the board.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s internal audit department periodically reviews the anti-bribery and corruption programme. There is evidence that the results of audits are shared with the Corporate Governance and Ethics Committee of the board of directors.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its entire anti-corruption and ethics programme is audited to ensure that it is consistent with high standards of best practice and the specific business risks facing the company. There is also not clear evidence that a specific individual or department holds ownership and responsibility for implementing recommended changes from audits.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating and resolving incidents, including any whistleblowing reports received via its independent third party operator. The company also commits to providing whistleblowers and employees who submit reports with information on the conclusion of investigations. There is clear evidence that the company\u2019s investigations are documented. <\/p>\n
However, the company receives a score of \u20181\u2019 because, although there is clear evidence that the company collects summary data on investigations, it is not clear from publicly available information that this data is reviewed by a central body, or that a central body reviews the status of investigations on a regular basis.<\/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 and states that its investigative process is reviewed on a continuous basis. The company also clearly states that staff tasked with conducting investigations are properly qualified and trained to perform the function. The company states that the Corporate Governance and Ethics Committee handles complaints related to the company\u2019s investigative procedure and states that if unsatisfied employees are able to escalate complaints on the investigative process through other reporting channels. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that either the company\u2019s Chief Ethics and Compliance Officer or General Counsel are responsible for informing the board-level Corporate Governance and Ethics Committee of any identified instances of potential criminality. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available 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 investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training that outlines the principles of the Code of Conduct and anti-corruption policy, including the whistleblowing options available to employees. The company states that employees are required to undertake refresher anti-corruption training every year. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company reviews its anti-corruption training programme on an annual basis, and that it uses the results of such reviews to update the programme where necessary. The company indicates that it measures training completion rates. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it has further procedures in place to measure and review the effectiveness of its anti-corruption training and communications programme specifically, for example by conducting staff surveys or targeted audits of these aspects of its programme at least every three years.<\/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-corruption principles to promote behaviour in line with the company\u2019s values. The company provides some publicly available information on its compensation structures for incentives, which includes a portion of an annual incentive based on adherence to the company\u2019s ethics principles; however it is not clear from publicly available information that the company adopts a similar approach to incentives for all employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company publicly commits to support and protect employees who refuse to act unethically in situations which result in a loss of business for the company. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
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 evidence that this non-retaliation policy extends to all employees, including those engaged by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that it commits to assure itself of employees\u2019 confidence in its non-retaliation commitment through surveys or other clearly stated means. This could include monitoring the usage statistics of whistleblowing channels across different parts of the organisation or conducting independent anonymised employee surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a third party operated whistleblowing service. These channels are available in relevant foreign languages and additionally allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence that the company\u2019s reporting channels are available to all employees in all jurisdictions where the company operates, and there is nothing to suggest that the reporting channels are not available for third parties and joint ventures. There is clear evidence that the company\u2019s reporting channels are available to suppliers. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy clearly covers conflicts of interest concerning government relationships, outside employment opportunities and employee relationships. This policy applies to all company employees and board members.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, actual, potential and perceived. The company indicates that potential or actual conflict of interest declarations are reviewed and overseen by its ethics and compliance department, which is ultimately accountable for the handling and implementation of individual cases and mitigations. The company also provides examples of potential conflicts of interest which would lead to recusals. In addition, the company states that in the event that an identified conflict of interest concerning a director cannot be mitigated then the director would be required to resign.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. There is also no publicly available evidence that the company provides a description of potential punitive measures that may be applied for breaches of its conflicts of interest policy.<\/p>\n
It is noted that the company indicates that it has separate policies on conflicts of interest and their review processes, which may contain further information, but these documents are not publicly available.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy and accompanying procedures which include controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. The company states that officials cannot discuss employment opportunities unless they have disqualified themselves from responsibilities in which they would be active in work concerning the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its policy regulating the hiring of former government officials also applies to former and current politicians, including non-US government officials, nor that any discussion of employment opportunities with former or current public officials requires senior ethics and compliance officer sign off. <\/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":"
There is evidence that the company does not make corporate contributions to support political organisations, and this policy applies company-wide to all employees. There is evidence that the company is associated with a voluntary Political Action Committee (PAC) in the United States, which is managed and overseen by a board of directors. <\/p>\n
Since the company is associated with a PAC in the United States, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes information on the indirect donations made through its Political Action Committee (PAC) in the United States, by providing a direct link to the Federal Election Commission website where full details of such expenditure can be found. There is evidence that the company does not make corporate political contributions through direct expenditures.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has policies and procedures regulating its charitable activities, including set criteria for donations. The company also discloses some high-level data on the total amount of money donated to charitable and philanthropic initiatives, although there is no clear evidence that this data is published annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes further details of its charitable donations, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. It is also not clear that the company\u2019s policy includes further controls to reduce the risk of bribery and corruption, such as conducting due diligence on recipients or requiring senior approval.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a company-wide policy and procedures covering lobbying. However, the company receives a score of \u20181\u2019 because the policy regarding lobbying is unclear and does not provide a general description of standards of conduct and desired behaviours that lobbyists must adhere to. No specific control mechanisms are described. It is also unclear if the company\u2019s policies covering lobbying also apply to board members and third parties. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes details of the topics on which it lobbies in the United States, without making a clear statement on lobbying activities in other jurisdictions. The information provided is accurate up to the last quarter of the previous reporting year. Also, the company does not provide supporting details of the aims and significant topics or the activities that it has carried out in support of specific legislative acts or campaigns.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
The company provides limited details of lobbying expenditure, correct up to the last reported financial year. The company receives a score of \u20181\u2019 because it provides no clear summary of total global lobbying expenditure or a summary of its expenditures on lobbying activities within the United States. Its global lobbying expenditure or lobbying activities outside of the United States are unclear. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality, which specifically addresses risks associated with gifts and hospitality given to\/received from domestic or foreign public officials.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not clearly specify different financial or proportional limits or different approval procedures for different types of promotional expenses. Additionally, there is no clear evidence that all gifts and hospitality above a certain threshold 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":"
There is evidence that the company has a specialist procurement programme that oversees its supplier relationships. There is clear evidence that this department is ultimately responsible for providing oversight of the company's supplier base and that this is the main body responsible for all supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers. The company indicates that it conducts due diligence on third party intermediaries, but it is not clear from publicly available information that similar standards are in place for suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that all suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that suppliers must adhere to its code of conduct and encourages suppliers to have anti-corruption policies which mirror those of the company\u2019s and an equivalent ethics and anti-corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its policy provides further details of the practical measures that it takes to ensure that suppliers have robust anti-corruption programmes in place. There is also no clear evidence that the company carries out audits or assessments of its suppliers\u2019 anti-corruption programmes, nor that it assures itself of suppliers\u2019 adherence to anti-corruption standards and principles during the onboarding stage or on a regular basis thereafter.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is evidence to indicate that the company expects its suppliers to conduct all business ethically and with integrity and. However, there is no clear publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of subcontractors throughout the supply chain, for example through clear audits, contractual clauses or dedicated training.<\/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 the associated disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence to indicate that the company states has implemented policies and measures to regulate agent conduct and to mitigate against and control the corruption risks associated with agents.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its policy contains details of specific measures used to control and regulate agent conduct. In addition, it is not clear from publicly available information that its policies include measures to verify that the in each instance the use of an agent is used to perform a legitimate business function. It is also not clear that the company\u2019s policies covering agent behaviour apply to its subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence both prior to engaging third parties and agents and on an ongoing basis throughout the business relationship. The company indicates that, based on a prevalence of high-risk factors, certain high-risk agents and intermediaries are subject to enhanced due diligence. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that it will not engage or terminate its engagement with an agent if a red flag identified during 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 ultimate beneficial ownership of agents and intermediaries. <\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company\u2019s third parties are prohibited from engaging in bribery and corruption, as outlined in its Code of Conduct. There is also clear evidence that the company includes audit rights in contracts with agents and third parties to detect, prevent and control breaches. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that the company\u2019s contracts with such entities include clear 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, nor that it has procedures in place to mitigate such risks.<\/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 and 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, incidents or the associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company clearly states that it conducts anti-bribery and corruption due diligence on its joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is evidence that the company has policies requiring joint venture partners to adhere to high ethical standards but receives a score of \u20180\u2019 because there is no evidence that the company makes a clear commitment to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. It also makes no clear statement that it includes audit or termination rights in joint venture contracts. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company makes a clear commitment 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 makes a clear statement regarding offset contracting activities. There is no clear evidence that the company has a dedicated department overseeing and managing offset commitments.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company clearly states that it conducts 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 details of offset agents and brokers involved in its offset activities. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes details of the beneficiaries of indirect offset projects. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence to indicate that the company performs enhanced due diligence checks on intermediaries in high risk markets. The company, however, receives a score of \u20181\u2019 because it does not clearly state that it uses corruption risk assessments more broadly to inform its 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 subsidiaries, which provides information on the country or jurisdiction\/state in which the company is incorporated. There is evidence that the company publishes this information on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes information on its percentage ownership of each subsidiary or holding, nor information on the country of operation of each company. It is also not clear that the data published represents all of its holdings nor does it indicate which companies are significant subsidiaries or joint venture partners. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly traded on the New York Stock Exchange (NYSE) and therefore it is not required to disclose information on its beneficial ownership. The company also discloses information of all its shareholders holding a stake greater than 5% in its annual reporting documents. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company publishes information on its major customers, to indicate that the United States government accounted for 85% of its total sales for the most recently reported financial year. However, the company receives a score of \u20181\u2019 because it is clear from public available information whether these figures represent defence sales or overall company sales in commercial or other areas. <\/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\/860","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=860"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=860"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}