There is evidence that the company has a publicly stated anti-bribery and corruption statement, which outlines its stance against any form of bribery or corruption within the organisation. It is clear that this statement is authorised and endorsed by the company\u2019s CEO. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. The company\u2019s policy applies to everyone within the company including those at subsidiaries and controlled entities. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has a executive-level committee \u2013 the Business Ethics Committee (BEC) \u2013 that is ultimately responsible for the oversight of the company\u2019s anti-bribery and corruption programme. This includes reviewing reports on the programme\u2019s performance, along with the results of internal audits, and there is evidence that it 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 \u2013 the Group Director Business Ethics & Corporate Responsibility, also referred to as the Group Compliance Officer \u2013 has ultimate responsibility for implementing and managing the anti-bribery and corruption programme. This individual has a direct reporting line to the Business Ethics Committee. There is evidence of reporting and feedback activities between this person and the committee as part of the company\u2019s reporting structure, through the attendance and participation at committee meetings on at least a quarterly basis. <\/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 that informs the design of its anti-corruption and bribery programme. The company indicates that it conducts risk assessments on an ongoing basis and in response to any major changes in the regulatory environment. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
The company states that its Group Internal Audit function conducts regular reviews of its business ethics programme. The results are reviewed by the Business Ethics Committee, with the findings used to update the company\u2019s programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available evidence show frequently audits are conducted and whether they take place at least every two years. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents and that it has a specific procedure in place to deal with whistleblowing cases. The company indicates that allegations may be reported to the Business Ethics Committee, although it is unclear whether this committee reviews summary information for all investigations. There is evidence that the company takes steps to ensure the independence of its investigations. <\/p>\n
The company commits to putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome. In addition, there is evidence that a central body is responsible for reviewing investigations. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its incident investigations and whistleblower cases. While the Business Ethics Committee is kept informed of evolutions in the company\u2019s procedures for handling investigations, it is not clear whether these procedures are reviewed at least every three years. There is no evidence that staff conducting investigations are properly trained and qualified, nor is it clear that the company has a procedure in place to handle complaints about the investigation process.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company commits to reporting material findings of bribery and corruption to the board, although there is some evidence that a managerial committee receives reports on allegations. There is also no evidence that the company publicly commits to reporting material findings to the relevant authorities, nor that it has an appropriate senior individual who would be responsible for evaluating such decisions.<\/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 any associated disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options. The company indicates that this training is provided to all employees.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear how frequently this training takes place or whether employees are required to undertake refresher courses at least every three years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training for employees based on an assessment of their role and exposure to corruption risk. The company states that it ensures that persons in sensitive positions have guidance on how to conduct business responsibly. However, it is unclear whether they are provided with a training programme that is tailored to their role\u2019s risk exposure and which are all the high risk groups identified in (a), (b) and (c) in the question. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s rewards for employees incorporate ethical principles. The company states that employee performance incentives cannot be in place if they are only achievable through unethical behaviour. <\/p>\n
However, further information about how the company ensures this in practice is not publicly available. There is no evidence to suggest that incentives are designed to reward behaviour in line with the company\u2019s ethical values, as identified through performance appraisals or conduct in the work place. It is also not clear whether financial incentive schemes are required to be proportionate to employees\u2019 salaries in the case of high risk employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company commits to supporting and protecting employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is no evidence that the company has a publicly available policy of non-retaliation against employees who report bribery and corruption incidents. However, there is no clear evidence that this policy extends to those employed by the group as third parties, suppliers and joint venture partners. There is also no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides whistleblowing and advice channels for its employees to report concerns or allegations of bribery and corruption. The company states that it will treat all concerns confidentially. In addition, there is evidence that the company\u2019s channels are sufficiently varied to allow employees to raise concerns across the management chain. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it offers an external channel for employees to report outside of the organisation, for example one operated by an independent third party. It is also not clear whether reports may be made anonymously. The company indicates that it schannels are available to all employees but it is not explicitly clear that they are available in multiple languages or to the employees of third parties, suppliers and joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy on conflicts of interest which applies to all employees and covers actual, potential and perceived conflicts. However, there is no publicly available evidence that the company\u2019s policy addresses the risks arising from specific categories of conflicts, such as employee and government relationships, financial interests and other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is no clear evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that employees must disclose potential conflicts to their manager, but it does not provide further details on its management or oversight systems. <\/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 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 to not make any corporate political contributions. The company indicates that this applies to both financial and in-kind donations to any political parties, organisations or individual politicians. In the United States, there is evidence that that the company is associated with a Political Action Committee (PAC).<\/p>\n
Since the company 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":"
The company publishes a clear statement that it does not make corporate political donations. However, the company is associated with a Political Action Committee (PAC) in the United States, and there is no evidence that it discloses any information on its PAC disbursements, either directly on its website or by including a link to federal disclosures. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a detailed policy and procedure on charitable donations and sponsorships. The company\u2019s policy includes criteria for donations and a requirement that all donations must be properly documented. However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes full details of its charitable donations and sponsorships, such as the name, amount and country of each recipient entity. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available 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 any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence its policy addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. However, there is no clear evidence that the procurement department is the main body responsible for oversight of the company\u2019s supplier base, nor is there 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":"
There is some evidence that the company has formal procedures in place to conduct annual risk based due diligence on its suppliers. There is some evidence to indicate 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. However, it is not clear from publicly available information that the company\u2019s due diligence includes checks on the beneficial ownership of suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company requires that its suppliers be aware of its Business Ethics Policy. The company indicates that it only does business with suppliers that adhere to ethical business principles. However, the company receives a score of \u20181\u2019 because there is no evidence to indicate how the company assures itself that its suppliers to have anti-bribery and corruption policies in place that meet a high standard. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no 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 associated disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy covering the use of agents, which includes due diligence and a requirement for the agent to certify their compliance with the company\u2019s ethics principles. The company\u2019s policy extends to all controlled subsidiaries and joint venture partners. In addition, this policy addresses corruption risks that may be associated with the use of agents, such as ethics compliance, remuneration and payments. <\/p>\n
However, there is no clear 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. The company stipulates that agents must be assigned clear duties, however it is not clear that this includes ensuring the legitimacy of their use. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has procedures to conduct due diligence on its agents prior to engaging them, and the company indicates that such checks include business ethics. However, it does not indicate whether this due diligence is anti-bribery and corruption focused or based on an assessment of risk. There is also no evidence that this due diligence 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":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents, nor is there evidence that 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":"1","comments":"
There is some evidence that, as part of its contractual arrangements, the company requires that agents certify their compliance with its business ethics principles. However, the company receives a score of \u20181\u2019 because there is no evidence that its contracts with these entities include anti-bribery and corruption clauses to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that remuneration for business advisers must be proportionate to the complexity of the project and relative to the market rate in the given jurisdiction. <\/p>\n
However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it requires that remuneration is made 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 investigations, incidents or disciplinary actions involving its agents. <\/p>\n"},{"question":100,"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 on all of its joint venture partnerships. The company clearly indicates that this includes establishing the ultimate beneficial ownership of the partner company. There is some evidence that due diligence is tailored according to the level of risk facing the company. <\/p>\n
However, there is no evidence that due diligence 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 some evidence that the principles outlined in the company\u2019s Business Ethics Policy apply to joint venture partnerships. In addition, the company states that in some cases joint ventures may implement different ethics policies but indicates that the standards must be equivalent to its own Business Ethics Policy. <\/p>\n
However, there is no publicly available evidence that the company requires the inclusion of anti-bribery and corruption clauses in its contracts with joint venture partners. <\/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 its joint ventures, for example, by 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":"0","comments":"
There is no evidence that the company specifically addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring its offset activities. Although there is some evidence that the company has policies governing its use of agents for offset contracting, there is no evidence of broader policies and processes in place to mitigate the risks associated with offset contracting as a whole.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is some evidence on the company has formal procedures in place to conduct due diligence on its offset advisors, through the same procedures outlined for business advisers. However, the company does not clearly indicate that such checks include establishing ultimate beneficial ownership or verifying that the use of an offset agent is based on a legitimate rationale. There is also no evidence that the company\u2019s policy on due diligence extends to other aspects of its offset obligations, such as checks on any partner company or companies. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with or on its behalf. <\/p>\n"},{"question":106,"commitment_area":14,"score":"1","comments":"
The company publishes some information on its global offset activities on its website, providing some examples of projects. However, this information is not published to a sufficient level of detail that the beneficiary may be identified. It is also unclear whether this list includes all of the company\u2019s offset activities, including indirect offset projects, or whether it is current and regularly updated. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no clear publicly available evidence that the company acknowledges the corruption risks of operating in different markets. The company indicates that its risk assessment procedures includes assessments of market conditions and changes in the regulatory environment, however, it is not clear whether this includes corruption risks and it does not provide any further information on its risk management procedures for different markets. There is also no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a list of its subsidiaries and affiliated entities. The company indicates in its Business Ethics policy that it operates through several national companies, however it does not provide publicly available details of these fully and\/or non-fully consolidated holdings. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes information on its major shareholders on its website, indicating that it is owned by three major European companies. There is evidence that all three of these companies are publicly listed on regulated markets as identified in the scoring criteria, and therefore the company is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. <\/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 indicates that its customers are mainly government authorities or international bodies, but it does not provide a breakdown of its defence sales by customer to any degree of detail.<\/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\/863","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=863"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=863"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}